Five crypto hubs, compared.

A common wrapper for token issuers, protocol foundations and DAOs, used to hold a protocol's treasury and contract on its behalf.

• A company with separate legal personality that may cease to have members if it keeps at least one supervisor, so there need be no owner
• Its constitution can give rights and powers to members, directors, supervisors, founders or others, which lets projects give token-holder governance legal effect
• Cannot pay dividends or distributions to members; its objects need not benefit anyone, and beneficiaries have no rights over its assets unless the constitution grants them
• Its secretary must be a qualified person licensed to provide company management services in Cayman
• Not regulated by CIMA as such: selling newly created tokens to the public in or from Cayman, or providing exchange, transfer or custody services, needs VASP registration or a licence

The operating or holding company of exchanges, custodians, developers and token projects, and an eligible entity for a VASP registration or licence.

• Must carry on its business mainly outside the Islands and may not trade with the public in Cayman unless it holds a licence to do so
• No public register of members and no requirement to hold its annual general meeting in Cayman
• Share capital may be in any currency or several currencies, with shares of nominal or no par value
• Tax neutral: no corporation, capital gains, payroll or withholding taxes, and it may apply for an undertaking against future taxes under the Tax Concessions Act
• A company incorporated under the Companies Act can register or be licensed as a VASP, so the same entity can hold the CIMA authorisation

Crypto fund platforms and issuers that want to keep separate strategies or asset pools ring-fenced inside one company.

• An exempted company that can create any number of segregated portfolios, each with its own assets and liabilities
• Assets of one portfolio are protected by statute from the creditors of the company's other portfolios
• Remains a single legal entity: portfolios have no separate legal personality
• Its name must include SPC and each portfolio must be designated as a segregated portfolio, SP or S.P.
• Registration as an SPC does not affect CIMA's power to decide whether it needs a licence under the regulatory laws

A common structure for closed-ended crypto venture and token funds.

• At least one general partner, which bears the partnership's debts, and limited partners whose liability is limited unless they take part in running the business
• May not do business with the public in Cayman except as needed for its business outside the Islands
• The General Registry states that no income or capital gains tax applies to the partnership or its partners
• A closed-ended ELP fund must register with CIMA under the Private Funds Act; since March 2026 its interests can be issued as digital investment tokens

Crypto hedge funds register as open-ended mutual funds and venture or token funds as closed-ended private funds; tokenised funds issue their interests on a blockchain.

• Funds investing in crypto are regulated as funds by CIMA, which counted 13,187 mutual funds and 18,360 private funds on 30 September 2026
• Since 24 March 2026 a tokenised mutual fund issues digital equity tokens and a tokenised private fund digital investment tokens, without VASP Act registration for that issuance
• Tokenised funds must disclose token risks in the offering document, control transfers through the operator and confirm their token records to CIMA every year
• The carve-out covers only the fund's own token issuance; other virtual asset services it provides still fall under the VASP Act

The usual vehicle for token issuers, group holding companies and operating companies; DAO projects often pair it with a foundation set up elsewhere, as BVI law has no foundation company.

• Formed through a licensed registered agent, which keeps the company's registered office in the BVI; one director is enough
• Records, including the register of members, may be kept in electronic form, and shares can be issued in classes and series
• No corporate income or capital gains tax; economic substance rules apply only to relevant activities such as holding, financing or IP business
• Issuing and selling its own tokens is generally outside the VASP Act, but providing exchange, custody or transfer services for others needs FSC registration even if done wholly abroad
• Beneficial ownership information is filed with the Registry under regulations in force since January 2025

Used as a governance entity for DAOs and protocol projects that want no shareholders, with guarantee members instead of owners.

• Members give a guarantee, stated in the memorandum, payable only if the company goes into liquidation
• Can be formed without authority to issue shares, so no member need hold an economic stake
• Articles can direct surplus to the project's purposes and give guarantee members a supervisory role
• Same registered agent, director and filing rules as other BVI business companies
• Not regulated by the FSC unless it carries on VASP or SIBA business

Used for crypto funds with several strategies or share classes, and other structures that need assets and liabilities ring-fenced by portfolio.

• Needs prior written FSC approval to incorporate or register as an SPC
• Assets and liabilities of each segregated portfolio are kept apart from other portfolios and from the company's general assets
• One legal entity: portfolios are not separate legal persons
• Open to insurers, recognised or registered funds and, since October 2018, companies that are not licensees
• 160 regulated SPC funds were registered at 31 March 2026

Lighter-touch starting points for managers launching a first crypto fund with a small investor base.

• Incubator funds: sophisticated private investors only, up to 20 investors and US$20 million of net assets
• Approved funds: up to 20 investors and US$100 million of net assets
• Approved by the FSC rather than recognised as a private or professional fund
• An incubator fund that outgrows its limits must convert to a private, professional or approved fund or wind down
• 181 incubator and 468 approved funds were registered at 31 March 2026

Open-ended crypto hedge funds for professional investors and closed-ended token and venture funds.

• Professional funds: professional investors only, with a minimum initial investment of US$100,000
• Private funds: no more than 50 investors, or offered on a private basis only
• Private investment funds are the closed-ended equivalent, recognised by the FSC since 31 December 2019
• A crypto fund is regulated as a fund under SIBA; VASP registration is a separate question that arises if it provides virtual asset services to others
• 858 professional, 272 private and 447 private investment funds were registered at 31 March 2026

Most firms on VARA's register are free zone companies, with names ending in FZE, FZCO or DMCC, among them Binance FZE, OKX Middle East Fintech FZE and Payward FZCO (Kraken).

• Two licences: the free zone authority incorporates the company and issues its commercial licence, and VARA issues the VASP licence; a commercial licence alone does not permit virtual asset activity
• The applicant files an Initial Disclosure Questionnaire through the free zone, and VARA's Approval to Incorporate, which does not permit operating, comes before the VASP licence
• The DWTC Free Zone offers FZCO, FZE and branch forms, with a one-year non-operational virtual assets licence until VARA grants its licence, then an operational licence
• The DMCC Crypto Centre had more than 800 member companies at the end of 2025

VASPs that want to operate on Dubai's mainland form a company licensed by the DET; licensees with LLC names include CoinCorner Virtual Assets Broker & Dealer Services L.L.C. and Daman Virtual Asset Brokerage LLC.

• The DET issues the commercial licence and VARA the VASP licence; DET branches have accepted applications for VARA-regulated activities since May 2023
• VARA says an LLC or free zone company is preferable and does not accept applications from sole proprietorships
• Virtual asset proprietary trading is a DET commercial licence that needs a no objection certificate from VARA
• As with free zone licensees, VARA licensees can be registered by default with the CMA to serve the rest of the UAE

Blockchain projects, DAOs and Web3 foundations use it to issue tokens and fund ecosystem development; the IOTA Ecosystem DLT Foundation, registered in November 2023, was the first.

• An ownerless legal person run by a council of two to 16 members, with at least one founder and an optional guardian
• May issue utility tokens and run governance through token voting and smart contracts; a white paper, and a tokenomics paper if it issues tokens, are filed on registration
• Minimum initial assets of USD 50,000, which may be paid in fiat currency or FSRA-recognised stablecoins but in no other form
• No physical presence is required, but it must have a registered ADGM company service provider unless the Registrar exempts it
• May not carry on activities that need FSRA permission; regulated business is done through a separately licensed subsidiary

Used to preserve and manage assets and plan succession, but not to conduct commercial activities; the DLT Foundation was created in 2023 for projects that issue tokens.

• A separate legal person with no shareholders, at least one founder and a council of at least two members; a guardian becomes compulsory once the last founder has died
• Minimum initial assets of USD 100
• The names of councillors, beneficiaries and any guardian are held confidentially by the Registrar, subject to disclosure to public authorities
• A non-exempt foundation must appoint an ADGM-licensed company service provider
• Overseas foundations can migrate into ADGM

The operating company of FSRA-authorised virtual asset firms and fiat-referenced token issuers such as Laser Digital (AD) Limited and Paxos Issuance MENA Ltd.

• The Registration Authority incorporates it and issues its commercial licence only after the FSRA has given in-principle approval
• At least one shareholder, individual or corporate, and at least one director who is a natural person
• At least one authorised signatory who is a UAE or GCC national or holds a UAE residence visa
• A registered office in ADGM under a lease valid for one year from the date of the commercial licence
• A foreign company can instead register an ADGM branch, whose activities must match the parent's; AMINA Bank AG holds its virtual asset permissions through one

A passive holding company used to ring-fence assets and liabilities, for example to hold a group's subsidiaries or to issue securities.

• Formed as a private company limited by shares or a Restricted Scope Company, with a commercial licence for special purpose vehicle activities only
• Cannot conduct operational business or hire staff
• Must show a connection to the UAE or the GCC, such as regional ownership, assets in the region, or securities listed or traded in ADGM
• A non-exempt SPV must appoint an ADGM company service provider; subsidiaries of FSRA-authorised firms are exempt
• The FSRA generally expects an issuer making an offer of digital securities to be incorporated in ADGM

The usual vehicle for a DABA licensee, token issuer or group holding company owned from outside Bermuda; forming one gives no right to carry on crypto activity.

• Not bound by the rule that local companies be at least 60% Bermudian-controlled; share capital in any currency
• Needs no separate section 129A licence from the Minister to carry on digital asset business in Bermuda once licensed under DABA
• Must have a Bermuda-resident director, secretary or resident representative
• Equity issues and transfers involving non-residents need BMA exchange control permission unless a general permission applies
• Can hold a tax assurance to 31 March 2035, which no longer protects against the 15% corporate income tax

An alternative to the exempted company for operating and issuing entities whose owners want members and an LLC agreement instead of shareholders and bye-laws.

• Separate legal entity that continues even if it has no members
• Managed by its members in proportion to their profit interests, unless the LLC agreement appoints managers
• The LLC agreement can create classes or groups of members with their own rights and votes
• An exempted LLC can hold the same 1966 tax assurance and denominate interests in any currency
• Subject to DABA and the DAIA like any company; its own ICO regime was repealed in 2020

Ring-fencing client or product pools inside one company; On Re SAC Ltd. and Excellar International SAC Ltd. hold DABA licences.

• Assets linked to a segregated account meet only that account's liabilities and are protected from other creditors
• Accounts are not separate legal persons; the company acts for each account
• A company outside insurance needs the Minister's approval to register as a SAC
• Must appoint a segregated account representative
• The BMA's guidance for DABA applicants names the SAC as a bankruptcy-remote structure

Running several digital asset businesses or tokenised products as separate companies under one umbrella; Cor Prime, Meli and Kimber Digital Assets ISACs and ISAs hold DABA licences.

• Since 22 October 2021 each incorporated segregated account is itself a company with its own memorandum and bye-laws
• Companies engaged in digital asset business may register as an ISAC without the Minister's approval
• The Registrar keeps a public register of ISACs and their accounts
• Where the ISAC or an account is a financial institution, the BMA must not object to registration

The status a Bermuda company, LLC or partnership needs before a public token offering, where it is not issuing tokens as a business.

• Authorisation for a fixed period on a business plan and a published issuance document
• Private placements to 150 or fewer persons, qualified acquirers or professionals fall outside, with a placement declaration
• Qualified acquirers include individuals with $1 million net worth and companies with $5 million of assets
• Companies also need the Minister of Finance's consent under the Companies Act
• The BMA proposed in April 2026 an explicit exemption for tokenised funds

Crypto and tokenised funds, which are registered or authorised as funds rather than licensed as digital asset businesses.

• Classes include private funds, Professional Class A and B funds, professional closed funds and authorised funds
• A fund whose manager is licensed under the Investment Business Act 2003, or by a recognised regulator, can claim DABA exemption by notifying the BMA
• The BMA proposed in April 2026 to allow tokenised fund registers and exempt the administrators running them from DABA
• The BMA consulted in July 2026 on funds using recognised stablecoins for treasury, settlement and collateral